ML18066A558
| ML18066A558 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/07/2018 |
| From: | - No Known Affiliation |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 82FR52944 00159, NRC-2017-0211 | |
| Download: ML18066A558 (2) | |
Text
Blount, Barbara
Subject:
FW: Docket ID NRC-2017-0211 Sirs & mesdames:
Tin cans are no way to store nuclear waste. A much more appropriate thick walled canister as used by other countries using nuclear plant energy is much more appropriate. I endorse the document attached from SanOnofreSafety.org.
This material is thoroughly researched. Following its recommendations should replace your present guidelines before half of California becomes an evacuation zone due to a Fukushima-like event resulting from the deadly combination of earthquake and/tsunami.
Date: January 2, 2018 Comments to NRC Docket ID NRC-2017-0211, NUREG-2215 NRC Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities Draft, November 2017 https://www.nrc.gov/docs/ML 1731/ML 1731 OA693.pdf The NRC cannot meet its mission to "ensure adequate protection of public health and safety and the environment" if it continues to allow thin-wall wel ded canisters they admit are vulnerable to cracks, that cannot be fully inspected (inside or out), and cann ot be repaired, maintained and monitored to prevent (not just detect) radiological leaks. There is no adequate or proven detailed plan required to addres
.s major radiological leaks, or to address on-site rep lacement of containers: Seismic requirements for partial cracks is not addressed. See below webpage for details on the Holtec UMAX System planned for San Onofre and why this is an example of a system w ith major problems that should not be approved.
https://sanonofresafety.org/holtec-hi-storm-umax-'hu clear-waste-dry-storage-system/
Each canister contains about as much or more lethal Cesium-137 as released from the 1986 Chernobyl nuclear disaster, yet the NRC knows the boron metal in the canisters will not prevent the fuel from go ing critical if exposed to non-borated water from throu 1
SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03,
Add= j-er-e~S>>u-1" C J"uS.()
gh wall cracks (in storage or transport).
NUREG-2215 states it requires "conservative assumpt ions", "inspections", and admits to many "unknowns". NUREG-2215 is not "conservative", does not require adequate "inspections, and does not resolve the many "unknowns" that would be eliminate d if the NRC mandated and enforced critical safety requirements to inspect, monitor, maintain a nd repair (both inside and out) to PREVENT leaks.
Proven dry storage technology exists that meets cri tical basic safety requirements we expect in a car.
Does the NRC consider thin-wall canisters "conserva tive assumptions" compared to thick-wall casks? If so, why? Why does the NRC allow containers that do not meet these basic critical safety requirements?
Respectfully, Donna Gilmore, SanOnofreSafety.org donnagilmore@gmail.com 949-204-7794 Basic Safety Requirements Thin-wall canisters Thick-wall casks Thick walls No Gamma & neutron protection Requires vented concrete overpack Yes Transportable No transport with cracks.
10 CFR § 71.85 Yes Proven technology No. Conditions unknown. Most in use less than 15 yrs, a few 30 yrs.
Yes. Inspected and used over 40 years Author of Three Tides: Writing at the Edge of Being available from Wingspress.com "Writers, readers, teachers, and creative writing classes, take note: Cecile Pineda is an American original, a literary treasure.... Her prodigiously inventive and important work.. deserves a place in the forefront of American liteq1.ture." -- Jeff Biggers, in Bloomsbury Review NOTICE: Due to Presidential Executive Orders still not rescinded by President Obama, the National Security Agency may have read this email without warning, warrant, or notice, and 2